Meat Notice 2014-01 - European Union (EU) Product Integrity and Certification Requirements

Issue Date: 24 January 2014

Date of Effect: Immediate

Date of Expiry: 1 February 2015

Contact Officers:

Christine Coulson
Director, Operational Integrity
Export Meat Program
Ph 02 6272 3933
Email Christine Coulson

Glen Edmunds
Director
Export Meat Program
Ph: 02 6272 3933
Email Glen Edmunds

1. Purpose

The purpose of this notice is to:

Advise occupiers of EU listed establishments that arrangements for establishment validation of Request for Permits (RFPs) for the EU will be rescinded.
Detail new requirements for Department of Agriculture officers to perform RFP validation for product destined to the EU market from 1st March 2014.
Detail new requirements for Department of Agriculture officers to countersign Meat Transfer Certificates (MTCs) for EU eligible product from 1st March 2014.

2. Scope

This notice applies to meat and meat products exported to the EU from export registered establishments operating under:

the Export Control (Meat and Meat Products) Orders 2005 (EC(MMP)Os)
the Export Control (Prescribed Goods - General) Orders
the Export Control (Wild Game Meat and Wild Game Meat Products) Orders 2010

3. Definitions

Term	Definition
Export Permit	A permit for the export of meat or meat products given by the Secretary - Schedule 8 Part 1 Division III Clause 6 or Clause 7 of the EC(MMP)Os.
Export Permit application	Required information submitted to the government by the exporter, or their delegate, requesting an export permit – Schedule 8 Part 1 Division I of the EC(MMP)Os.
Department of Agriculture RFP Validator	A Department of Agriculture employed authorised officer who verifies the compliance of the information submitted in a RFP with the EC(MMP)Os.
Meat Transfer Certificate (MTC)	A document that accompanies meat and meat products being transferred between export registered establishments - Schedule 7 Part 2 of the EC(MMP)Os.
MTC Signatory	A person in management and control of the establishment who declares that the contents of the MTC are true and correct and the product meets the requirements of the EC(MMP)Os.
Department of Agriculture MTC Countersignatory	A Department of Agriculture employed authorised officer who countersigns an MTC after verifying that the information submitted in the MTC is in compliance with the EC(MMP)Os and EU requirements.
Request For Permit (RFP)	An electronic export permit application – Schedule 8 Part 1 Division I of the EC(MMP)Os.
RFP Signatory	The exporter or their delegate who declares that information submitted as part of an application for an export permit is true and complete - Schedule 8 Part 1 Division I Clause 2.1 of the EC(MMP)Os.
RFP Validation	The verification that the information provided in RFP is correct and complies with the EC(MMP)Os and EU requirements.

4. Actions and Responsibilities

4.1 Establishment Management must:

Immediately review the occupier’s approved arrangement against the contents of this meat notice specific to:
1. Load out inspection
2. The RFP creation process including filling in consignment information, verifying this information is correct and that the product is EU eligible, signing the declaration and completing the meat compliance statements
3. The MTC completion process including filling in consignment information, verifying it is correct and signing the declaration.
4. Record keeping requirements in support of the above activities
Ensure that the establishment approved arrangement complies with this meat notice so that these requirements can be implemented from 1 March 2014.
Ensure that:
1. MTC Signatories are recorded in the department’s Establishment Register (ER) database as persons in management and control.
2. RFP and MTC Signatories are specified in the approved arrangement.
3. RFP and MTC Signatories understand their legal responsibilities when performing these tasks and have received training relevant to these tasks.
4. RFP and MTC Signatories understand and can demonstrate how the establishment’s product integrity, traceability, MTC completion and RFP submission systems work.
Make records of training available to the department upon request.
Make available to the department copies of relevant records (either paper or electronic) including:
1. Daily kill sheets –containing property of origin information (Property Identification Codes), number of stock, type of stock (e.g. steer, heifer, cow, bull etc), market eligibilities, and the links to vendor declarations and relevant statuses from the National Livestock Identification System (NLIS) database
  Note: This information should be available within the establishment’s record keeping system for department verification for all markets and is usually linked to product codes.
2. Daily packing summaries of EU-eligible product (e.g. boning room carton record, product type [product codes], weight, and number of pieces where applicable)
3. Daily load-out agenda in advance
4. Load-out reports for each EU load (covering container number, carton counts, product description (product codes), pack date(s), slaughter dates, etc.)
5. Incoming MTCs and load-out reports for inter-establishment transfers of EU-eligible product
6. For independent processing facilities and cold stores: incoming MTCs, load-out reports and for boning rooms and meat product establishments, the daily packing summary
At least twice a year as part of the establishment’s internal audit and management review process, trace back and trace forward product identified on an EU health certificate to confirm that the product details were correct and the product remained EU eligible through all stages of production and export.

4.2 Establishment RFP Signatories must:

Have knowledge and understanding of the Export Control Act 1982 and relevant subordinate legislation, know the overseas listings of the establishment and the specific importing country requirements for those listed countries.
Know and understand the requirements in the occupier’s approved arrangement for preparing loads for export.
Be able to use the required information technology systems (including EXDOC, ELMER 3 and MICoR) effectively.
Understand and be able to demonstrate how the information in all the RFP fields is obtained for that processing/storage operation at the establishment.
Sign documents used to verify the accuracy of the information in an RFP and keep these records with a copy of the completed RFP.
Be identified within the occupier’s approved arrangement.
Maintain their access to EXDOC (monthly log-in to EXDOC is recommended to maintain active status

4.3 Establishment MTC Signatories must:

Have knowledge and understanding of the Export Control Act 1982 and relevant subordinate legislation, know the overseas listings of the establishment and the specific importing country requirements for those listed countries
Know and understand the requirements in the occupier’s approved arrangement for preparing loads for transfers
Be able to use the required information technology systems (including ELMER 3 and MICoR) effectively
Understand and be able to demonstrate how the information in each MTC field is obtained for that processing/storage operation at the establishment
Keep auditable records of the verification activities undertaken to support the signing of every MTC.
Be identified within the occupier’s approved arrangement

4.4 Departmental On-Plant Staff must:

Review proposed amendments to the ER database and, if appropriate, recommend changes to the Area Technical Manager (ATM) for approval
Review proposed approved arrangement amendments, and if appropriate, recommend changes to the ATM for approval
Ensure MTC Countersignatories and RFP Validators understand and can demonstrate how the establishment’s product integrity, traceability, MTC completion and RFP submission systems work
Review relevant records including the final kill sheets, production summaries, load-out agendas, load-out reports, completed MTCs, finalised RFPs and the quadruplicate copy of the health certificate (returned from regional office) to determine whether declarations provided by RFP and/or MTC Signatories are true and complete.
File reviewed records (as applicable) for each load
Ensure that all MTC Countersignatories and RFP Validators have completed the Product Traceability training module
Ensure that RFP Validators maintain their access to EXDOC (monthly log-in to EXDOC is recommended to maintain active status)
Conduct verification activities, countersign MTCs and validate RFPs in accordance with departmental instructional material

4.5 Area Technical Manager must:

Review recommendations for changes to occupiers’ approved arrangements and ER and approve as appropriate
Audit product integrity and export certification systems during the first audit of the occupiers’ approved arrangement after 1 March 2014
Ensure that all MTC Countersignatories and RFP Validators (both on-plant staff and inspection staff located in regional offices) have completed the Product Traceability training module
By 1 July 2014 and annually thereafter, verify whether the activities of on-plant staff countersigning MTCs and validating RFPs comply with the requirements of this meat notice

5. Requirements

5.1 Creation of RFPs in EXDOC

An occupier’s approved arrangement must include documented procedures detailing the process for creating an RFP and providing the RFP and supporting documentation to the departmental RFP Validator. Creating an RFP includes filling in consignment information, verifying it is correct, signing the declaration, completing the meat compliance statements
RFP Signatories must declare that the contents of the MTC are true, correct and complete and that the product meets the requirements of relevant export legislation and must also complete the two mandatory meat compliance statements to confirm the veracity of the declaration
The RFP Signatory is responsible for the accuracy of all information, declarations and statements in the RFP
Statements made by the RFP Signatory must not be false or misleading
Persons who make false or misleading statements to a Commonwealth entity may be prosecuted under the Criminal Code Act 1995 Part 7.4.
The RFP Signatory must supply copies of the supporting documentation to the relevant RFP Validator
Appendix 1 identifies information relating to the preparation of RFPs for the EU for inclusion in an occupier’s arrangement

5.2 RFP Validation Procedures

The departmental RFP Validator reviews the supporting documentation, including the declaration made by the RFP Signatory that the goods meet the requirements of the Export Control Act 1982and the intended importing country. Once satisfied with the integrity of the product based on the supporting documentation and their knowledge of the establishment operations, and the veracity of the declaration the validator can ‘validate’ the RFP
Establishments without on-site departmental presence are to contact their local regional office to arrange for RFP validation

5.3 MTC Verification and Signing Procedures

Occupiers’ approved arrangements must include documented procedures detailing the MTC completion process; including filling in consignment information, verifying its correctness and signing the declaration. MTC Signatories declare that the contents of the MTC are true, correct and complete and that the product meets the requirements of the Orders
MTC Signatories are responsible for the accuracy of all information on the MTC. Declarations must not be false or misleading; nor they be made without justification.

Note: Persons who make false or misleading statements to a Commonwealth entity may be prosecuted under the Criminal Code Act 1995 Part 7.4

Appendix 2 identifies information relating to MTC completion procedures for EU eligible product for inclusion in an occupier’s arrangement

5.4 MTC Countersigning Procedures

The departmental MTC Countersignatory will review the supporting documentation, including the declaration made by the MTC Signatory that the goods meet the requirements of the Export Control Act 1982 and the EU. Once the departmental officer is satisfied of the integrity of the product based on the supporting documentation and their knowledge of the establishment operations, the MTC can be countersigned
The MTC must be countersigned directly below the MTC Signatory’s declaration. The signature, printed name and position of the MTC Countersignatory and the date must be included
Establishments without on-site departmental presence are to contact their local regional office to arrange for MTCs to be countersigned

Glen Edmunds
Director
Export Meat Program
January 2014

Appendix 1

Information required in an occupier’s arrangement for creation of an RFP for the EU

The specific detail within the occupier’s arrangement for creation of an RFP may vary. The process must reflect the product integrity and traceability systems and operations used at the establishment and must be described within the arrangement. The arrangement should include the following information:

The process for appointing a company RFP Signatory (for loads for export to the EU). This includes the training procedures for creating an RFP
A list of all RFP Signatories for EU loads prepared at the establishment

The process for creating an RFP includes filling in consignment information, verifying the information is correct and the product is EU eligible, signing the declaration, completing the meat compliance statements and keeping evidence/records of the verification activities undertaken to create the RFP. Details required include:

How EXDOC is accessed and how the RFP is viewed
How the information in the RFP is initially obtained
Identifying establishment records relating to the product required to verify the accuracy information in the RFP and EU eligibility of the product, including but not limited to:
- Load-out reports, product scan reports, product source documents (incoming MTCs), results of any required product tests for specific markets
- Reports of cross checks performed to ensure correct counts, product descriptions, shipping marks, market access requirements (e.g. carton seals, official marks, establishment number, pack dates, slaughter dates), container number, seal, etc.
How the product details on the RFP are checked against the records to verify their accuracy
The process to be followed to ensure that the product meets all EU requirements
The basis on which the declaration is made that the goods meet the requirements of export legislation and the EU
The basis on which the meat compliance statements are answered
How the evidence/records used to justify the information/declaration/statements on the RFP are kept and can be accessed
How the departmental RFP Validator is notified that the RFP is ready for validation including what supporting documentation is provided to the RFP Validator and how it is provided
The procedures to be followed when the RFP information is not accurate or the product is not eligible for the intended destination

To provide guidance on the scope of the verification activities, the following information in the RFP must be verified as being correct before validation of the RFP is requested

Product type
Product quantity
Packing establishment(s) registration numbers
Packing date(s)
Slaughter dates(s)
Importing country eligibility
Container number and official container seal number

Appendix 2

Information required in the occupier’s approved arrangement for MTCs for EU eligible product

The specific detail within the occupier’s approved arrangement for MTC preparation may vary. The process must reflect the product integrity and traceability systems and operations at the establishment and must be described within the arrangement. The arrangement should include the following information:

The process for appointing a company MTC Signatory (for MTCs for EU eligible product). This includes the training procedures for completing and signing MTCs
- MTC signatories must be in positions of Management and Control (see Clause 8.1 of the Export Control (Meat and Meat Product) Order 2005, and section 4.05 of the Export Control (Prescribed Goods — General) Order 2005)
A list of the establishment’s MTC Signatories
The process for completing an MTC including filling in consignment information, verifying its correctness, stating that the product is EU eligible and signing the declaration. Details required include:
1. How the information in the MTC is initially collected
2. The procedure for applying the correct market eligibility statement to the MTC
3. The process that the MTC Signatory follows to ensure that the declaration made about the information in the MTC is true and accurate including how they know that the product meets all Australian regulations and EU requirements
4. What company records relating to the product intended to be transferred are required for verification; including but not limited to:
  - load-out reports, product scan reports, product source documents (incoming MTCs), results of any required product tests for specific markets
  - reports of cross checks performed to ensure correct counts, product descriptions, market access requirements (e.g. carton seals, official marks, establishment number, pack dates, slaughter dates), truck registration number etc.
5. How the MTC Signatory keeps evidence/records of the verification activities they have undertaken to support their declaration of the truth and accuracy of the MTC and how this can be accessed
6. The procedure for signing the MTC
7. The procedures to be followed when the MTC information is not accurate or the product is not eligible for the intended destination